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PENINSULA GAMING PARTNERS
RESPONSES TO LOTTERY GAMING FACILITY REVIEW BOARD QUESTIONS
DECEMBER 10, 2010
Question 1: If economic markets seize up, what is the replacement mechanism for $50 million in financing?
In the event that the credit markets were to stop functioning and prevent Peninsula from accomplishing a $50 million tack-on to its existing senior unsecured notes, the company would pursue a mezzanine financing, bridge financing or a private offering of equity. While the company believes that the markets will continue in a relatively healthy state as they are today, we are extremely confident of our ability to finance from the different sources mentioned.
Peninsula is one of the best known regional gaming credits in the market. Its bond issues have consistently traded well and currently trade above par at 106 and 109 (this equates to yields of 6.5% and 8.7%). These prices are both a reflection of (1) the strength of the capital markets today as well as the expectation of near- to mid-term market conditions, and (2) the market’s perception/evaluation of our company, any perceived risks or disruption to our operating results and in general the strong quality of Peninsula’s reputation in the marketplace.
Peninsula has accessed the capital markets seven times in the last 11 years to fund the development of its properties. During that time there have been a variety of capital market conditions experienced, and yet Peninsula has never failed to obtain the necessary capital.
Peninsula has spent approximately $5.0 million pursuing the management contract in the South Central Zone of Kansas. We would not have embarked upon such an effort if we believed there was any question as to our ability to finance this project.
Question 2: Information on the usage of the Dubuque college scholarship program.
Our scholarship program in Iowa is available to all graduating seniors in Worth County, Iowa, the location of our Diamond Jo Worth County property. We began offering this program in 2006. From 2006 through 2009, 376 of the 388 graduating seniors used our scholarship program, meaning 97% of graduating seniors attended college or other post-secondary education with help of our scholarship program.
Question 3: What is Peninsula’s plan on water and drainage for the casino site?
At the December 15, 2010 Lottery Review Board Meeting, Mr. Greg Schwerdt of Schwerdt Design, and Mr. Kurt Yowell of MKEC Engineering Consultants, Inc., will give an oral presentation summarizing in detail the new infrastructure that will be completed as part of Kansas Star project and how that new infrastructure will substantially improve drainage conditions for the landowners adjacent to our site A casino location. Mr. Christopher Young, the city engineer for the City of Mulvane, is attending the meeting and will be available to answer questions from the Lottery Review Board members as well.
We have also attached an Executive Summary prepared by MKEC that summarizes MKEC’s comprehensive drainage report that was previously filed as part of the application process. The attached Executive Summary provides a detailed description of our drainage solutions for our site A casino location.
Question 4: Provide any other marketing studies to clarify visitation rates or revenues.
We have attached the Independent Accountants Report prepared by Morowitz & Company, LLC, dated July 19, 2010 that was submitted as an exhibit to our initial license application, along with the addendum to that report, dated September 19, 2010 that was filed as an exhibit to Amendment No. 2, to our license application.
Mr. Morowitz is a respected gaming industry professional with over 20 years of financial, gaming and statistical analysis. This includes work for gaming industry leaders such as Penn Gaming, Hyatt Gaming, Harrah’s and Pinnacle, among others. He is also familiar with local markets, having performed analysis for Cordish Company with respect to the Kansas City gaming market, as well as for Penn’s application for the Wichita market, during early rounds of the application market.
Attached as additional exhibit to this document is a more detailed overview or Mr. Morowitz’ gaming industry experience, along with a comparison chart showing Mr. Morowitz’ revenue projections compared to Mr. Wells and Mr. Cummings.
You’ll see that Mr. Morowitz’ projections are more conservative than both Mr. Cummings and Mr. Wells. In 2016, Mr. Morowitz projects gaming revenue for the Kansas Star of $202 million compared to projections of $209 million for Mr. Wells and $213 million for Mr. Cummings.
For a more detailed view of Mr. Morowitz’ revenue projections you can review Mr. Morowitz’ complete revenue study and addendum provided herewith.
Question 5: Provide information related to the applicant’s approach and practices regarding responsible gambling.
Included below is a description of Peninsula Gaming’s corporate commitment to responsible gaming, which addresses the issues of compulsive gambling, underage gambling, and alcohol awareness. A copy of Peninsula Gaming’s corporate-wide Responsible Gaming Policy, and an example of the training program, as implemented at the property level, are included as exhibits to this document.
Peninsula’s Commitment to Responsible Gaming
While research shows that more than 98% of adults gamble for the entertainment it is intended to be1 unfortunately a small percentage of our guests will not gamble responsibly. Peninsula Gaming’s commitment to responsible gaming includes team member training, partnerships with local treatment providers, advertising treatment providers toll free phone numbers and more.
Team Training
Team members receive on-going responsible gaming education and training that supports an environment that keeps gaming fun. Team members are educated on self-exclusion programs, internal procedures for addressing problem gambling, the company’s responsible gaming policy and specific jurisdictional requirements during orientation. At Kansas Star, team members will be educated on the specific guidelines provided in K.A.R. 112-112 and all applicable forms. In partnership with local gambling treatment providers, team members receive updated training and participate in responsible gaming education updates through newsletters, internal postings and on-site visits from gambling treatment experts.
Responsible Beverage Service
Responsible beverage service training is an integral part of our commitment to responsible gaming. Front line food and beverage team members and others who interact with guests are each required to become TIPS certified. TIPS (Training for Intervention ProcedureS) is the global leader in education and training for the responsible service, sale, and consumption of alcohol. Proven effective by third-party studies, TIPS is a skills-based training program that is designed to prevent intoxication, underage drinking, and drunk driving. TIPS’ Casino Course provides real-life scenarios in a casino setting. Participants complete a multiple-choice exam. Participants who pass the exam receive a certification card, valid for three years. (Every Peninsula property adheres to the highest standards of responsible beverage service whether the jurisdiction requires it or not; Louisiana requires training; Iowa does not and Kansas does not)
Dedicated Advertising to Promote Responsible Gaming
Our casinos include helpline information in each paid advertisement, on player development collateral, on all in-house display ads, at our Player’s Clubs, casino cashier stations and on ATM’s in each casino. Working with local problem gambling treatment providers, our designated leadership team including security, human resources, marketing, regulatory compliance and beverage staff are
responsible for promoting the toll free helpline and updated responsible gaming information to employees and customers. Our corporate policy to dedicate advertising space to responsible gaming works. Last year the majority of callers to 1-800-BETS-OFF (Iowa’s toll-free gambling referral and information line) credited a casino when asked where they heard about the helpline.2
Providing Help and Heightened Awareness for Responsible Gaming Education
Peninsula Gaming casinos participate in statewide self-exclusion programs which encourage problem gamblers to seek help and prohibits them from entering the gaming floor. Security administers the program at each property. Security team members update entries received from individuals and local gambling treatment providers.
Our casinos participate in Responsible Gaming Education Week each year. This American Gaming Association event raises awareness for responsible gaming education. Responsible Gaming Education Week provides another opportunity for our casinos to work with local treatment providers to promote dialogue surrounding scientific research on gambling and health to communicate to and educate patrons, employees and the general public.
1 Health in Iowa, Annual Report, from the 2007 Iowa Behavioral Risk Factor Surveillance System, page 59
2 http://www.1800betsoff.org/common/pdf/annual_sum_2010.pdf, 1-800-BETS OFF FY 2010 Data Summary
Question 6: Provide information related to the applicant’s approach and practices regarding managing alcohol issues.
Please see question 5 for a comprehensive answer regarding Peninsula Gaming’s corporate commitment to responsible gaming and the attached materials, which address Peninsula Gaming’s company-wide policy and procedures for managing alcohol issues.
Question 7: Provide a summary of the pre-marketing strategy.
In response to this question we have included a copy of the Kansas Star’s Pre-Opening Demand & Stimulation Marketing Plan as an exhibit to this document.
Exhibit List:
1. MKEC Executive Summary – Kansas Star Drainage Plan 2. Morowitz & Co. Experience and Summary PowerPoint 3. Morowitz & Co. Independent Accountants Report 4. Addendum to Morowitz & Co. Independent Accountants Report 5. Peninsula Gaming Responsible Gaming Corporate Policy 6. Example – Peninsula Gaming Property-Level Training Program 7. Kansas Star Pre-Opening Demand & Stimulation Marketing Plan
Kansas Star Casino – Proposed Drainage System Executive Summary
1. Site Description The Kansas Star Casino development consists of a 202 acre parcel of land (Site) that is bordered by 119th Street (K‐53) on the north, Broadway Road / US‐81 (Broadway) on the west and 140th Avenue on the south. To the east is the I‐35 (KS Turnpike) right‐of‐way, which contains a borrow pit that occasionally is filled with water. Northeast of the Site is a winery. 2. Drainage Study Purpose and Methodology The purpose of this drainage study is to determine what improvements are necessary for the proposed development in order to have no adverse impact on the surrounding drainage systems and to correct Site related capacity issues. To do this, pre‐ and post‐development runoff conditions were studied on the surrounding and downstream watersheds totaling 1,887 acres. 3. Existing Drainage Conditions Currently, the northern part of the Site drains southwest and into the ditch on the east side of Broadway. Runoff then flows south toward existing twin 36‐inch x 60‐inch corrugated metal arch pipe culverts under 140th Avenue adjacent to Broadway. The southwest part of the Site also drains to the southwest and into the same twin culverts. The southeast part of the Site, the winery and the turnpike right‐of‐way drain into the twin 30‐inch reinforced concrete pipe culverts under 140th Avenue adjacent to the Kansas Turnpike. During major rainfall events, runoff occasionally flows south over 140th Avenue about midway between the KS Turnpike and Broadway. 4. Proposed Site Drainage Systems As shown on the attached proposed drainage system drawing, runoff from the proposed development will be conveyed in an independent drainage system consisting of three major swales: one each on the west, south, and east edges of the development. The western swale will be independent of and parallel to the existing east Broadway ditch. Runoff from the west one‐half of the Site will be conveyed by the western swale to the southern swale and then east into a new detention basin. Consequently, flows conveyed by the existing Broadway Road ditch section downstream to 140th Avenue will be limited to runoff from the Broadway right‐of‐way and the residential area and vacant land west of Broadway. The eastern swale will drain the eastern half of the development and the I‐35 right‐of‐way/ borrow pit area into the detention basin. The southern swale will be independent of the Broadway ditch, will parallel 140th Avenue and will accept runoff from the 140th Avenue right‐of‐way. 5. Proposed Detention Basin and Swales The entire proposed development of 202 acres, the I‐35 right‐of‐way/ borrow pit area of about 24 acres, and 24 acres of the winery will drain into the new, 29.8‐acre, dry bottom detention basin located at the southeast corner of the development. Water in said basin will be drained by a combination of gravity flow and pumping to the existing twin 30‐inch reinforced concrete pipe culverts under 140th Avenue
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adjacent to the Kansas Turnpike. For all storms, including the 100‐year event, the peak pumping and gravity flow rate will be limited to 25‐cfs. Said rate is less than the capacity of existing twin culverts and the Kansas Turnpike Authority has previously agreed to said rate. A new agreement will be sought for The Kansas Star Casino. Post development conditions will be as follows:
Detention Area – 29.8 acres (Basin and Swales) • Ground Elevation at Top of Basin = 1249.00 feet • Floor Elevation = 1243.00 feet (at lowest point) • Maximum Depth of Basin = 6.00 feet • Bottom of Clay/Top of sand layer = 1242.00 feet • Elevation of Historic High Water Table = 1238.00 feet • Storage Capacity of Basin and Swales = 140.1 acre‐ft (6,104,200 cubic‐ft or 226,028
cubic‐yards) Water Surface Elevations in the Detention Basin:
• 2‐year storm event – 1245.28 feet (2.28 feet water depth) • 5‐year storm event – 1245.89 feet (2.89 feet water depth) • 10‐year storm event – 1246.32 feet (3.32 feet water depth) • 100‐year storm event – 1247.94 feet (4.94 feet water depth)
Overflow elevations:
• I‐35/Kansas Turnpike: 1250.00 feet (edge of pavement elevation). The water elevation for the 100‐year storm event is therefore 24.7 inches below the edge of pavement elevation.
• Low Point on 140th Avenue (east of Broadway): 1248.68 feet. The designed system thereby provides 8.9‐inches of freeboard during the 100‐year storm event. As a result of the construction of the proposed detention basin, overtopping of 140th Avenue will be eliminated for storm events up to and including the 100‐year storm event. Runoff overtopping 140th Avenue under pre‐ and post‐development conditions is as follows:
2‐year 5‐year 10‐year 100‐year Condition (cfs) (cfs) (cfs) (cfs)
Existing Flow Rate 29.50 92.50 135.70 254.70
Proposed Flow Rate 0.00 0.00 0.00 0.00 6. Proposed Improvements to Existing Drainage System Proposed improvements include the replacement of the existing twin 36‐inch x 60‐inch corrugated metal arch pipe culverts under 140th Avenue adjacent to Broadway with a 10ft x 3ft reinforced concrete box culvert. Replacement of these corrugated metal arch pipe culverts, combined with the reduction in flow volume achieved by the separation of the proposed flows will improve the hydraulic conditions at the discharge end of the reinforced concrete box culvert under Broadway just south of 144th Avenue. As noted above, no runoff from the proposed development will be allowed to drain into the culverts under
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140th Avenue adjacent to Broadway and as a result, the existing drainage system under 140th Avenue will experience reduced flow rates as follows:
2‐year 5‐year 10‐year 100‐year
Condition (cfs) (cfs) (cfs) (cfs)
Existing Flow Rate 152.50 158.00 160.80 166.70
Proposed Flow Rate 114.92 124.16 129.44 144.31
Reduction 24.60% 21.40% 19.50% 13.40% 7. Residual Downstream Impact Analysis The drainage study was continued downstream to a point where the proposed development was approximately 10% of the overall watershed area. This is typically done in order to determine any residual downstream impacts the proposed development may cause. The terminal point is located at the northeast corner of 120th Avenue and Broadway. It was found that as a result of the proposed improvements, the existing drainage system at 120th Avenue and Broadway will also experience reduced flow rates as follows:
2‐year 5‐year 10‐year 100‐year
Condition (cfs) (cfs) (cfs) (cfs)
Existing Flow Rate 880.62 1457.51 1860.10 3340.90
Proposed Flow Rate 840.11 1323.13 1683.02 3034.54
Reduction 4.60% 9.20% 9.50% 9.20% 8. Proposed Earthwork / Site Grading Excavation of the detention basin and all swales will yield approximately 233,000 cubic yards of material. The grading required for pavement and foundation construction will yield an additional 100,000‐cubic yards of excavated material. To construct the Site to the finished grades (not including the turnpike interchange or roundabouts) will require about 320,000‐cubic yards of compacted (15% allowance) fill material. The on‐site earthwork will therefore be balanced, with some material remaining. The off‐site turnpike interchange will require additional fill. If additional fill material is needed, lowering the bottom of the detention basin 1‐ft to an elevation of 1242.00 will provide about 23,000 cubic yards of additional material. Lowering the bottom would increase the capacity of the detention basin, and provide an additional foot of freeboard beyond the 100‐year storm event for a total of two feet. The detention basin could also be widened, providing further material and storm water storage capacity. As noted above, the historic high water table is at 1238.00 feet at the basin. With a 7 foot maximum depth below the existing grade of 1249 feet, the bottom of the basin would still be 4 feet above the historic high water table.
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9. Summary of Proposed Improvements Re‐routing all runoff from the proposed development to an independent drainage system and conveying said runoff to a detention basin will provide the following benefits for all storm events through and including the 100‐year storm event:
• Runoff from the Site into the existing east Broadway ditches will be eliminated. • Overtopping of 140th Avenue will be eliminated. • Downstream peak flow rates will be significantly reduced. • Culvert capacity under 140th Avenue at Broadway will be increased. • The existing reinforced concrete box culvert under Broadway just south of 144th will have
improved hydraulic conditions at its discharge end.
CONFIDENTIAL 1
PENINSULA GAMING PARTNERS, LLC ADDENDUM TO MARKET STUDY KANSAS STAR CASINO, HOTEL & EVENT CENTER SUMNER COUNTY, KANSAS Additional Gaming Revenues from Equine Event Center September 19, 2010 Prepared by: Morowitz Gaming Advisors, LLC
CONFIDENTIAL 2
EXECUTIVE SUMMARY
On July 19, 2010 we completed a market study for a proposed casino and equine event center in Sumner County, Kansas. This report is meant as a supplement to our original report. We were asked by the management of Peninsula Gaming, LLC to re-visit our findings with respect to the proposed equine event center, specifically with respect to additional analysis that was completed by Crossroads Consulting Services with respect to the number of events, and potential visitation at the events center. We have prepared a Pro-forma analysis of the visitation and potential additional gaming revenues that would be realized by the proposed Kansas Star Casino Hotel & Event Center utilizing the findings in the Crossroads report. In our original report, it was anticipated that the Equine Event Center would be utilized approximately 12 times annually for equine type events (with additional usage for concerts, etc.). The Equine events are expected to result in additional tourist visitation because many of the patrons of these events visit from further distances than for concerts. Based on the Crossroads study, there are expected to be 26 to 31 equine related events at the facility annually. Based on the increased equine utilization of the center, tourist trips related to equine events would increase considerably compared to our initial study from 97,275 to 198,700 in Phase 1b and from 162,125 to 231,150 in Phase 2. In terms of gaming revenue, the facility could realize additional incremental gaming revenues above those forecasted in our initial study of $4.138 million in 2016 (stabilized Phase 1b) and $2.152 million in 2018 (stabilized Phase 2). The incremental revenues, which were determined using the same assumptions as those used our initial study and updated for additional visitation and events, are included in the following table.
CONFIDENTIAL 3
Analysis of Incremental Gaming Revenue from Equine Events
Phase 1b Stabilized
Per Original Market Study
Phase 1b Anticpated Utilization
Per Crossroads Net Increase
Phase 2 Stabilized
Per Original Market Study
Phase 2 Anticpated
Utilization Per Crossroads Net Increase
Gaming Revenues from Spectators
Number of Equine/Rodeo Events 6 21 15 10 24 14 Number of Spectators 2,500 1,945 (555) 2,500 1,978 (522) Days 3.00 3.48 0.48 3.00 3.48 0.48 Total Spectator Days 45,000 142,000 97,000 75,000 165,000 90,000 % Adults 60.0% 60.0% 0.0% 60.0% 60.0% 0.0%% from > 120 miles 24.0% 24.0% 0.0% 24.0% 24.0% 0.0%% Who Gamble 71.0% 71.0% 0.0% 71.0% 71.0% 0.0%Daily Gambling Budget 250$ 250$ -$ 260$ 260$ -$
Annual Gaming Revenue from Spectators at Non-Equine Rodeo Events 1,148,801$ 3,625,115$ 2,476,314$ 1,992,022$ 4,382,447$ 2,390,426$
Less Spectators Staying on Site (25) (25) - (50) (25) 25 Daily Gaming Budget 250$ 250$ -$ 260$ 260$ -$ Gaming Revenue Adjustment (112,363)$ (455,695)$ (343,332)$ (389,676)$ (541,835)$ (152,159)$ Net Incremental Gaming Revenue From Spectators at these Events 1,036,438$ 3,169,420$ 2,132,982$ 1,602,346$ 3,840,613$ 2,238,267$
Gaming Revenues from ParticipantsParticipants at Level 1 Events 238 1,260 1,023 238 1,260 1,022 Number of Events 6 5 -1 10 6 -4Number of Days 3.00 5.00 2.00 3.00 5.00 2.00 Total Participant Days 4,275 31,500 27,225 7,125 37,800 30,675 % from > 120 miles 95.0% 95.0% 0.0% 95.0% 95.0% 0.0%
% Who Gamble 71.0% 35.5% -35.5% 71.0% 35.5% -35.5%Daily Gambling Budget 250$ 250$ -$ 260$ 260$ -$
Annual Gaming Revenue from Participants 757,890$ 2,792,226$ 2,034,336$ 1,314,181$ 3,486,038$ 2,171,857$ Less Participants Staying on Site (50) (50) - (50) (50) - Daily Gaming Budget 250$ 250$ -$ 260$ 260$ -$ Gaming Revenue Adjustment (224,726)$ (911,390)$ (686,664)$ (389,676)$ (1,083,669)$ (693,994)$ Gaming Revenues from Participants at Level 1 Events 533,163$ 5,050,255$ 4,517,091$ 924,505$ 6,242,981$ 5,318,476$
Participants at Level 2 EventsNumber of Events 6 16 10 10 18 8 Number of Participants 2,000 453 (1,547) 2,000 453 (1,547) Days 4.00 3.48 (0.52) 4.00 3.48 (0.52) Participant Days 48,000 25,200 (22,800) 80,000 28,350 (51,650) % from > 120 miles 95.0% 95.0% 0.0% 95.0% 95.0% 0.0%% Who Gamble 35.5% 35.5% 0.0% 35.5% 35.5% 0.0%
Daily Gambling Budget 250$ 250$ -$ 260$ 260$ -$
Annual Gaming Revenue from Participants 4,042,079$ 2,122,091$ (1,919,987)$ 7,008,965$ 2,483,802$ (4,525,163)$ Less Participants Staying on Site (75) (75) - (150) (150) - Daily Gaming Budget 250$ 250$ -$ 260$ 260$ -$
Gaming Revenue Adjustment (449,453)$ (1,041,589)$ (592,136)$ (1,558,702)$ (2,438,256)$ (879,553)$
Gaming Revenues from Participants at Level 2 Events 3,592,626$ 1,080,502$ (2,512,124)$ 5,450,262$ 45,546$ (5,404,716)$
Incremental Visitor Days Related tro Equine Events 97,275 198,700 101,425 162,125 231,150 69,025
Incremental Gaming Revenue from Rodeo Events 5,162,228$ 9,300,177$ 4,137,949$ 7,977,114$ 10,129,140$ 2,152,026$
CONFIDENTIAL 4
LIMITING CONDITIONS Morowitz Gaming Advisors, LLC (MGA) has been engaged by Peninsula Gaming Partners, LLC (client) to prepare a market analysis in connection with gaming and related development at the Kansas Star site in Sumner County, Kansas. We were provided with a development budget and programming for the project by the management of Peninsula Gaming Partners, LLC. We were not engaged to verify the development budget, or the optimal programming for the project. Our conclusions in this report are based on those amounts provided by the client and if the development budget, or programming should change or be incorrect, the conclusions herein could change materially. We take no responsibility for the development budget, or programming in this report. Certain information included in this report contains forward-looking estimates, projections, and/or statements. Morowitz Gaming Advisors, LLC has based these projections, estimates and/or statements on our current expectations about future events. These forward-looking items include statements that reflect our existing beliefs and knowledge regarding the operating environment, existing trends, existing plans, objectives, goals, expectations, anticipations, results of operations, and future performance. Further, statements that include the words: “may,” “could,” “should,” “would,” “believe,” “expect,” “anticipate,” “estimate,” “intend,” “plan,” “project,” or other words or expressions of similar meaning have been utilized. These statements reflect our judgment on the date they are made and we have no duty to update such statements after the date of this report. Supply and demand projects are, by their very nature, only estimates and “best guesses” of what may occur in the future. Any number of variables may change over time and methodologies that work under certain conditions may not work in other or changing conditions. Additionally, some of the assumptions used in our study will inevitably not materialize and unanticipated events and circumstances may occur; therefore, actual results achieved during the period of our analysis will vary from our projections and the variations may be material. Accordingly, MGA accepts no liability in relation to the estimates or projections provided herein. This report is intended as a supplement to the Peninsula Gaming Partners, LLC application to the Kansas Lottery Gaming Facility Review Board. It is intended solely for that purpose. This report is not intended for any other third parties and Morowitz Gaming Advisors, LLC has no responsibility to anyone except the management of Peninsula Gaming Partners, LLC. We have no duty to update the conclusions in this report for events and circumstances occurring after the date of this report.
Over 20 years of diversified financial, gaming, statistical analysis and consulting experience in 15+ jurisdictions
Former Industry Director of Wharton School of the University of Pennsylvania Program for Gaming Industry Executives
Familiar with Kansas and Oklahoma markets
Cordish casino in Kansas City market
Penn Gaming in Wichita and Cherokee market
Gravity Model
Borgata Pinnacle Trump Marina
Resorts International Foxwoods Hard Rock
Mohegan Sun Penn Gaming Florida Gaming Corp
Harrah's Hyatt Gaming Dover Downs
$0
$50,000,000
$100,000,000
$150,000,000
$200,000,000
$250,000,000
2012 2014 2016
Projected Gaming Revenue
Morowitz Wells Cummings
Conservative revenue estimates
PENINSULA GAMING, LLC RESPONSIBLE GAMING POLICY
Policy: All casinos owned and/or operated by Peninsula Gaming, LLC have
an obligation to our employees, our patrons and to the public to make responsible gaming part of our day-to-day operations. The Company is committed to making responsible gaming an integral part of its day to day operations by providing guidance to our team members regarding compulsive gambling, underage gambling and alcohol awareness.
Scope: This policy applies to all properties owned and/or operated by
Peninsula Gaming, LLC. This policy is to be considered the MINIMUM standard. Any and all Local or State laws or regulations shall supersede this document when applicable.
A. Employee Areas and Training.
1. All properties will educate new employees on all areas of responsible gaming including but not limited to applicable state regulations within 30 days of employment.
2. All properties will conduct employee training at least annually in all areas
of responsible gaming (Compulsive gambling, Underage gambling and Alcohol Awareness).
3. Training records will be maintained by the Human Resources
Department for a period of three (3) years.
4. All properties will implement communication programs for employees to improve understanding of responsible gaming and related policies and procedures.
5. All properties will distribute to new employees, brochures describing
responsible gaming and where to find assistance. Copies of these brochures will be made available to all employees.
6. All properties will post responsible gaming awareness signage bearing a
toll-free help-line number at various locations where employees congregate.
B. Operations:
1. Promoting Responsible Gaming.
a. All properties will make available brochures describing compulsive gambling and where to find assistance. These will be available and visible in gaming areas and at ATMs.
b. All properties will make available on all Web sites information regarding where to find assistance. All properties will display in gaming areas and at ATMs signage that can be easily read bearing a toll-free help-line number.
c. All properties will make available to patrons and employees information generally explaining the probabilities of winning or losing at the various games offered by the casino.
d. All properties will provide opportunities for patrons to request in writing that they not be sent promotional mailings and for revocation of their privileges for specific casino services such as:
• Casino-issued markers • Player club/card privileges • On-site check cashing
e. Individuals may voluntarily exclude themselves from all gaming at our casinos. Any such exclusion will be for the time period required by the applicable jurisdiction. All properties reserve the right to exclude a patron from gaming, without a request from the patron. This includes patrons who have not specifically excluded at one of our properties, but have self-excluded through a local State office or local Gaming Association.
2. To Prevent Underage Gambling and Unattended Minors in Casinos.
a. All properties will communicate the legal age to gamble through
appropriate signage and/or brochures. Underage patrons shall not be allowed in the gaming areas of the properties.
b. Employees working in relevant areas will receive training in appropriate procedures for dealing with unattended children, underage gambling, and the purchase and consumption of alcohol and tobacco by minors.
c. If a child appears to be unsupervised in a non-gaming area, security will be contacted and remain with the child while reasonable steps are taken to locate the parent or responsible adult on property. If efforts are unsuccessful, security personnel will contact an appropriate third party, such as the police department and release the unattended child to their care.
3. To Serve Alcoholic Beverages Responsibly.
a. All properties will observe a responsible beverage service policy including the following elements:
• Not knowingly serve alcoholic beverages to a minor. • Not knowingly serve alcoholic beverages to a visibly
intoxicated patron. • Make a diligent effort not to permit gaming by a visibly
intoxicated patron. b. All properties will ensure proper training or certification of
employees, on responsible beverage service, whose job duties involve direct patron interaction. If an outside program is used for such training, then the refresher training can be based on the programs guidelines.
D. To Advertise Responsibly. This policy applies to the advertising and marketing of all properties.
1. All advertising and marketing will: • Contain a responsible gaming message and/or a toll-free help-line
number where practical. • Reflect generally accepted contemporary standards of good taste. • Strictly comply with all state and federal standards to make no
false or misleading claims.
2. Advertising and marketing materials will not: • Contain cartoon figures, symbols, celebrity/entertainer
endorsements and/or language designed to appeal specifically to children and minors.
• Feature current collegiate athletes. • Feature anyone who is or appears to be below the legal age to
participate in gaming activity. • Contain claims or representations that gaming activity will
guarantee an individual’s social, financial or personal success. • Be placed in media where most of the audience is reasonably
expected to be below the legal age to participate in gaming activity.
• Imply or suggest any illegal activity of any kind. • Be placed in media specifically oriented to children and/or
minors. • Appear adjacent to, or in close proximity to, comics or other
youth features, to the extent controlled by the property. • Be placed at any venue where most of the audience is normally
expected to be below the legal age to participate in gaming activity.
E. To Provide Oversight and Review.
1. The Internal Audit Department, on an annual basis, will conduct a review of each property to determine compliance with this policy. As part of this review, the property will also be tested on any applicable local laws or regulations pertaining to any area of responsible gaming.
Problem Gambling PGL is very concerned for both our guests and team
members who feel they may have a gambling problem. If a guest or fellow team member approaches you in regard to problem gambling, notify your supervisor. Your supervisor has been trained on how to respond to these issues. If the guest or team member does not want to wait for a supervisor, then encourage them to take the problem gambling literature with them so they know help is available. The team member will advise the guest that help can be provided.
Compulsive and Problem GamblingTraining & Orientation
Alcohol AwarenessPromote Responsible Drinking Objective To ensure that all team members make a reasonable effort to
ensure that our guests drink responsibly.
Alcohol and its Effects Alcohol affects different people in different ways, and its effects can even differ for the
same person at different times. Alcohol is a depressant – not a stimulant. Alcohol dissolves the fat of nerve cells, increasing the liquids in those cells, making
them temporarily inactive while putting some of the brain cells out of commission. The brain is most dramatically affected by alcohol. Below are the stages of impact on
the different parts of the brain:
Part of the Brain EffectCortex Inhibitions, thinking, reasoning and decision making. Judgment.Cerebellum Posture, motor control and coordinationLimbic System EmotionsBrain Stem Heartbeat and respiration
Alcohol AwarenessPeople are affected by alcohol in the following areas:
1. Inhibitions People with lowered inhibitions become more talkative, relaxed, over-friendly, lose their self-control and sometimes display mood swings.
2. Judgment People exhibiting poor judgment behave inappropriately, such as ordering doubles, using foul language, telling off-color jokes or annoying others.
3. Reactions Glassy, unfocused eyes and people talking and moving very slowly, forgetting things, lighting more than one cigarette, losing their train of thought and slurring their speech result from slowed reactions.
4. Coordination Stumbling or swaying, dropping belongings and having trouble picking up a drink can indicate a loss of coordination.
Underage Gamblers
A person under the age of twenty-one (21) is prohibited from gambling. While it is the primary responsibility of Security to keep underage individuals off of the casino floor, it is the responsibility of ALL team members on the casino floor to identify possible underage gamblers. If you suspect a guest is under 21 and gambling, contact Security.
Underage GamingPatron DeterrentOBJECTIVES
During this training session the following topics will be covered to ensure that all team members are familiar with the policies and procedures set forth to prevent underage gaming.
Identify who is considered an underage individual Proper signage Acceptable forms of identification Verifying identification Methods to detect false identification Characteristics and tactics of underage individuals attempting to
gain access Discovery of underage individual on gaming premises
Amelia Belle CasinoPolicy on Underage Gaming The Company shall provide training classes to employees on a regular basis.
These classes shall be mandatory for all employees regardless of position or department. It is every employee’s responsibility to prevent underage gamers from accessing the gaming areas.
It is the policy of the Amelia Belle Casino, not to allow anyone under 21 years of age to gamble in our casino.
No employee of the Company shall allow an underage individual to gain access to the gaming premises.
PURPOSE – UNDERAGE GAMING
To ensure full compliance with Federal, State, and Local Gaming Regulations, as they pertain to methods for prevention and deterrence, to prohibit access to gaming premises by underage individuals.
Procedures – Underage GamingEntrances to Gaming Premises A Security Officer will be stationed at all casino entrances at all times to ensure
that our zero tolerance will be obtained. Any individual who appears to be thirty-five years of age, or younger, must
produce valid photographic identification.Signage
A. Signs prohibiting access by underage individuals to gaming premises shall be conspicuously posted at all locations providing public access to the gaming premises.
B. The signs shall read:“Amelia Belle Casino has zero tolerance for underage gaming. Any individual trying to gain access to the gaming premises may face a $500.00 fine and up to six months imprisonment.”
Other Information on Signs Stipulate the date which you must be born on or before in order to lawfully gain
access to the gaming premises. Stipulate the accepted forms of identification necessary to gain access to the
gaming premises.
Acceptable forms of IDAcceptable Forms of Identification (limited to the
following): Valid State Issued Driver’s License Valid State Issued Identification Card Valid United States Military Identification Card Valid United States Office of Immigration &
Naturalization Card Valid United States Issued Passport
Discovery of Underage Individual on Gaming PremisesIn the event that an underage individual is discovered on the
gaming premises, the following procedures should be employed:
Team member who discovers the underage individual will report it immediately to their Supervisor. Give location, and description of the individual.
The Supervisor will immediately contact the Security Supervisor and Surveillance.
Surveillance shall be provided with the physical description and name of the individual.
The Security Supervisor shall follow normal eviction procedures. The Division or Gaming Commission, when appropriate, shall be
notified and the individual detained, until the arrival of the appropriate authorities.
Compulsive/Problem Gambling
National Council on Problem Gambling, Inc.
24 Hour Confidential National Helpline
1-877-770-STOP
Compulsive/Problem GamblingDuring the training session the following topics will be
covered:
Review Amelia Belle’s policy on Compulsive Gambling Purpose of policy and team member
awareness/responsibility What management and employees can do to assist a guest
in finding help Discuss the Louisiana Casino Gaming Division Definitions Stages and Progression of Compulsive Gambling Signs and symptoms
IntroductionThe Amelia Belle Casino wants to ensure all employees are aware of the signs of compulsive gamblers. Everyone should know compulsive gambling is an illness that can strike anyone, no matter what his or her social economic background is. By knowing the signs of compulsive gambling, and knowing help and treatment is available, Amelia Belle Casino employees will be better equipped to recognize compulsive gambling in professional and personal lives. This will also lead employees to urge those who are compulsive gamblers to seek help before irreparable harm can be done to individual’s lives and families.
Compulsive Gambling & Our GuestsCompulsive Gambling and Our Guests The Amelia Belle Casino promotes recreational gaming. We encourage
our guests to return often, and hope that they will enjoy themselves when they do. We must recognize however, that not all of our guest gambles for relaxation and entertainment. From time to time, guests will develop into compulsive gamblers.
Company Policy Statement – “Compulsive Gamblers” Compulsive gambling is considered a psychiatric disorder or
characterized as addictive and can be destructive mentally, physically and financially.
The Company recognizes that a small amount of our patrons/guests may suffer from this disorder.
The Company also recognizes it has no legal right to prevent these patrons/guests from patronizing our properties. However, we feel a moral obligation to recognize this behavior and curtail the compulsive gamblers destructive and/or disruptive actions when they patronize our properties.
We must be sure not to infringe upon our guests’ right to privacy and quiet enjoyment of life’s activities. The Company’s policy will focus on the following:
Provide training for managers, supervisors, and line employees who may come in contact with the compulsive gambler.
Ensure adequate signage is in place in prominent places throughout our properties, which reaches out to the compulsive gambler and provides them an avenue to deal with their behavior.
Establish and train employees to adhere to policies and procedures designed to discourage and prevent compulsive gamblers from gambling in our facilities.
Ensure that once a patron is identified as a compulsive gambler, that employees are trained to effectively deal with the patron and how to assist the patron in getting help.
Ensure that once a patron is identified as a compulsive gambler, that the patron is removed from Amelia Belle Casino’s mailing list and is unable to obtain credit.
Provide alcohol awareness training for employees to ensure compliance with required standards in conjunction with responsible gaming.
Managers will be the focal point for monitoring this addictive behavior and taking steps to insuring responsible behavior by the compulsive gambler when they are recognized. Steps can include:
A side conversation with the guest to address potential issues. Denying additional credit. Suspension of gaming privileges and/ or eviction. Through training and experience, the Company will rely on the judgment and actions of
the management team. Overall, the Company wants to promote an environment conducive to having fun and displaying responsible behavior.
Guest Elective OptionsVoluntary Self Limitation/Restriction/Exclusion
The Amelia Belle Casino is committed to promoting public awareness and education to providing information on available resources to those patrons who believe they may have a gambling problem. The Amelia Belle Casino maintains a program in compliance with State Gaming Regulations in each state it operates casinos.
State of Louisiana Gaming Regulation LAC 42:III.301E (3) Allows patrons to voluntarily self-limit themselves from certain activities and privileges,
which are provided as a service and convenience. Any patron electing to participate in self-limitation/restriction/exclusion can obtain the
appropriate form from Security. The patron will fill out the appropriate forms, have then notarized and mail the form to the Director of Compliance. These forms will be distributed to the appropriate departments.
Upon acceptance of the form, Compliance Officer will: Forward the original to the Security Department. Security will write report, photocopy the original for distribution, give the original to the
Database Manager to DAPS (disassociated patron) the patron in the player tracking system and distribute copies to the departments.
Credit will immediately adjust a patron’s check cashing and/or credit limit and file a copy in the respective patrons’ folder.
Update the chronological log and file that is maintained in the credit department for cross reference.
Definitions of GamblingThe following terms are used concerning compulsive gambling:
Recreational Gaming Betting or wagering, done on an occasional basis, when the primary goal is
relaxation and entertainment.Gambling Any betting or wagering, for self or others, whether for money or not, no matter
how slight or insignificant, where the outcome is uncertain or depends upon chance or skill.
Problem Gambling A level of gambling that brings problems and/or pain to the gambler and/or
his/her family.Pathological Gambling A progressive disorder characterized by a continuous or periodic loss of control
over gambling; a pre-occupation with gambling and with obtaining money in which to gamble; irrational thinking; and a continuation of behavior despite adverse consequences.
Compulsive Gambling An addictive illness in which the subject is driven by an overwhelming
uncontrollable impulse to gamble.
The “Hidden Illness” Compulsive gambling has been called the “hidden
illness,” because it is so hard to detect. Compulsive gamblers do not exhibit traits that make them easily distinguishable. People can be compulsive gamblers for years, and hide it from friends, family, business associates and the general public.
When does Entertainment turn into Addiction? Normally addiction does not happen overnight.
Before gambling becomes a real problem, the player goes through a series of stages and varying lengths and intensity.
Stages of Compulsive GamblingFirst Stage Winning The player derives enjoyment from the game and will occasionally win fairly
large sums of money. Gambling is synonymous with social contact and allows an individual’s self-esteem to grow. Spurred on by success, the player takes risks and starts borrowing small sums of money to maintain or even increase the stakes.
Second Stage Losing At the beginning of this stage, some players are able to control their losses.
Others soon overcome by an uncontrollable desire to make up the heavy losses that risk taking has inflicted. The money lost is almost always borrowed from family, friends, financial institutions or credit cards. Sometimes the person will even resort to lies and deception in order to get more money. Socially they become increasingly isolated and even will lose the trust of family members and close friends. In short, gambling has turned into an outright obsession.
Third Stage Despair and Desperation A person reaching this stage becomes agitated, irritable, and hyperactive. They
are unable to sleep, suffers loss of appetite and even a desire to live. Mental and physical exhaustion sets in, along with the feeling of desperation and feeling of helplessness.
Indicators of Compulsive GamblingIndicators of Compulsive Gambling Time and money primarily devoted to gambling Increase in time spent and places used to gamble Increase in size of bets Creating gambling occasions Increase in the intensity of interest in gambling Boasting, distorting, or lying about winnings Exaggerated focus on money and possessions Crisis related gambling Decreased interest in a broader range of activities and interests Frequent absences from work and home; withdrawal from family and
friends Excessive use of the telephone for some sort of gambling Mood shifts – withdrawal, irritability, anger Diversion of family finances Occupational and legal difficulties
What YOU Can DoYou May Observe a Guest Who: Argue with casino employees Beat on machines Try to borrow money from other guests Fall asleep at machines Appear to be in a trance-like state or “zoned out” May faint from lack of food Have poor personal hygiene Listen for trigger statements like “I don’t know what I am going to do, I have lost so
much.” Watch for guest who just look like they are no longer having fun
What YOU Can Do Provide the guest with a brochure that contains information to obtain help. Learn where
these important brochures are located at the property. If you can not find one, simply get a phone book and get the number.
The enclosed pages contain additional self-help tools that could assist you or a guest. Additional information can be obtained from the Human Resources Department.
SELF LIMITATION
PROCEDURES
AND
FORMS
SELF-LIMITATION PROCEDURESThe Amelia Belle Casino promotes responsible gaming and is proactive in assisting anyone who is identified as a pathological or problem gambler. Anytime a patron requests exclusion or promotes signs that are indicative of problem gambling then an immediate individual file will be initiated and maintained to account for all activity and correspondence. This individual file will be maintained by the Compliance Department and a copy of the file will be maintained in the General Manager’s office for immediate reference. A Self Exclusion Activity Log will be maintained within the noted file and all relevant events will be recorded on the log that pertain directly or indirectly to requested exclusion or problem gaming activity. All self-exclusion files will be maintained indefinitely.In addition, at anytime the property may be proactive and assertive at restricting or denying the gaming privileges of any patron identified as a pathological or suspected problem gambler. Once identified, then immediate suspension of gaming privileges, direct mail marketing, complimentary and amenities may ensue. All suspension of these noted privileges must be approved by the General ManagerThe following procedures will be followed anytime a patron seeks assistance with voluntary exclusion:
ON PROPERTY REQUEST FOR EXCLUSION:
• Any patron requesting exclusion from gaming privileges will be escorted to the Security Department to complete a “Request to Self-Limit Access” and “Eviction Notice” forms. The guest should be accompanied by the designated property representative for responsible gaming and offer any assistance that may be of use to the self-exclusion.
• Surveillance must be immediately notified of the self excluded persons presence and obtain video coverage of all relative events in relation to the exclusion/eviction.
• A Self Eviction checklist will be completed by the relative Security representative to ensure all procedures are adhered to or followed in conjunction with the exclusion/eviction.
• Surveillance and Security will obtain a photo of the patron for record retention and reference.
• Prior to filling out the form the patron will be advised that they will be considered a permanent eviction upon completion of the form and they may not be eligible for reinstatement .
• After advising the guest of her/his permanent eviction status, the following information should be obtained from the guest:
– Rapid Rewards Card or account number
– Current drivers license
• After the patron has completed the form the designated Security representative will review the form for accuracy and verify information recorded by the self-exclusion.
• Upon completion of the “Request to Self-Limit Access” a copy should be provided to the self-excluded patron if requested.
• Once the form is completed and reviewed for accuracy, the patron will be escorted from the property.
On Property Request for Exclusion cont.• Security will complete an incident report and attach as part of the completed exclusion package.
The original packet will be forwarded to the Compliance Department.
• Compliance will forward a copy of the Request to Self-Limit Access, Eviction Notice and copy of a photo to Marketing. The Marketing Database representative will enter the exclusion information into the database and record the exclusion as a “Voluntary Exclusion”. In addition, the patron will be marked “NO MAIL” in the system and all direct mail marketing will be discontinued within 90 days.
• The Database representative will add any correlative remarks into the system. Once the remarks and status have been entered into the system, the Marketing Department will send confirmation to the Compliance Department to be placed in the excluded patron’s file.
• A photo of the patron requesting exclusion along with a copy of the “Request to Self-Limit Access” will be forwarded to the following departments:
– Marketing/Database - Security - General Manager
– Compliance - Cage/Credit Office
– Slots - Players Club
– Surveillance - Table Games
• Security, Surveillance and Compliance will receive a copy of the “Eviction Notice” form to be retained with the excluded patron’s records.
• A copy of the “Request to Self-Limit Access” and “Eviction Notice” will be reviewed by Security and Surveillance personnel and the appropriate representative of each department will complete an incident report documenting the self-exclusion. A copy of each report will be forwarded to the Division.
OFF PROPERTY REQUEST FOR EXCLUSION:
• All received letters or notices of intent regarding self-exclusion will be immediately forwarded to the Compliance Department for evaluation.
• The Director of Compliance will review the exclusion request with the General Manager and determine validity and ensuing action.
• If the request is determined valid then the Director of Compliance will draft a formal letter responding to the exclusion request and forward to the requesting patron.
• A self-limitation form and eviction notice acknowledgement form will accompany the formal letter sent to the patron requesting exclusion.
• The letter should request that the patron return a copy of his/her driver’s license along with a recent photograph.
• The letter must be sent certified mail and the certified receipts should be retained by the Director of Compliance.
• All returned self-limitation forms will be immediately forwarded to the Director of Compliance.
• The self-limitation forms must be notarized and once returned will be examined for noted requirements and accuracy. Once the document is reviewed and no discrepancies are found to be present then it will be placed in the appropriate corresponding file for future reference and retention.
OFF PROPERTY REQUEST FOR EXCLUSION:• A copy of the completed exclusion form will be provided to the Marketing Department.
Once received by Marketing then a Database representative will enter the exclusion information into the database and record the exclusion as a “Voluntary Exclusion.” In addition, the patron will be marked “NO MAIL” in the system and all direct mail marketing will be discontinued within 90 days.
• The Database representative will add any correlative remarks into the system. Once the remarks and status has been entered into the system then the Marketing Department will send confirmation to the Director of Compliance to be placed in the excluded patron’s file.
• A copy of the returned “Request to Self-Limit Access” and photograph of the exclusion (if available) will be forwarded to the following departments:
1. Marketing/Database 2. Security
3. Compliance 4. Cage/Credit Office
5. Slots 6. Players Club
7. Surveillance 8. Table Games
9. General Manager
• A copy of the “Request to Self-Limit Access” will be reviewed by Security and Surveillance and the appropriate representative of each department will complete an incident report documenting the self-exclusion. A copy of each report will be forwarded to the Division.
REQUEST FOR DIVISION EXCLUSION:If a guest approaches an employee requesting information on Division exclusion policies and regulations then the following procedures will apply:
• At least one designated person per shift will be on property at all times to assist any guest who requests information on “Division Exclusion.”
• Once a guest indicates the area interested in exclusion through the Division then the designated property representative will notify Surveillance immediately; Surveillance will contact the Trooper on call to advise him that a patron is requesting “Division Exclusion.”
• If desired, the guest will also be directed to the Security Department to complete a property “Request to Self-Limit Access” form and “Eviction Notice” form. All relative personnel should follow procedures referenced in the section “On Property Request for Exclusion” should the guest choose to be excluded from the property.
IMPORTANT:•Any request by a patron for responsible gaming or exclusion information relative to Division exclusion should be immediately reported to an agent of the Division.
•Any request by a patron for responsible gaming or exclusion information should be immediately reported to the Director of Compliance.
•The Director of Compliance will follow up on any information received as a result of responsible gaming or exclusion inquiries by guests.
•Any patron who completes the Division exclusion process may not apply for reinstatement of privileges for a period of five (5) years.
DIVISION EXCLUDED PATRONS ON PROPERTYIF A DIVISION EXCLUDED PATRON IS FOUND ON THE PREMISES THEN THE FOLLOWING
PROCEDURES SHOULD BE FOLLOWED:
• Security, Surveillance and the Division will be immediately notified regarding the presence of any self-exclusion that gains access to the gaming area.
• Once a self-excluded person has been identified then the excluded patron must be immediately removed from the gaming area and premises.
• Surveillance shall videotape all occurrences relating to the presence of exclusion.
• A Security and Surveillance report will be completed and forwarded to the Division.
• A photograph of the self-excluded person will be obtained and forwarded to the Division.
• Local law enforcement will be contacted in lieu of failed attempts to notify the Division for the purpose of statutory enforcement or ensuing arrest.
• A conjoining investigation by Security and Surveillance of the self-exclusion’s gaming activity will be conducted to determine if forfeiture of winnings is applicable per La.R.S.27:27.1E.
DIVISION EXCLUSION LISTING:The Division Exclusion listing will be periodically received from the Division and forwarded to the Director of Compliance. The Director of Compliance will ensure that all relative departments receive a photocopy of the Division Exclusion Listing to comply with Division minimum guidelines. Each department will maintain and utilize the Division Exclusion listing as a reference guide. The listing will be sent to the following departments:
1 Marketing/Database2 Security3 Compliance4 Cage/Credit Office5 Slots6 Players Club7 Surveillance8 Table Games9 General Manager
All individuals listed on the exclusion list will be researched in the database by marketing personnel. Once received by Marketing then a Database representative will enter the exclusion information into the database and record the exclusion as a DAP (disassociated patron). In addition, the patron will be marked “NO MAIL” in the system and all direct marketing will be discontinued within 90 days.
REQUEST TO SELF-LIMIT SERVICES:
Patrons may elect to self-limit specific services offered by the property such as check cashing rights, issuance of credit, Players Club membership, direct mail promotional material or complimentary allowances. Anytime a patron requests to self-limit one or all of these privileges offered by the property then the following procedures should be followed:
• Any patron requesting exclusion from gaming privileges will be directed to the Security Department to complete a “Request to Self-Limit Services” form. When possible, the guest should be accompanied by the designated property representative for responsible gaming and offer any assistance that may be of use to the self-limiting patron.
• Prior to filling out the form the patron will be advised that they may request reinstatement of suspended privileges at anytime thereafter. However, privileges may be restricted indefinitely as determined by management and if reinstatement is granted services may take 30 days to become effective.
• Upon completion a duplicate copy of the form should be provided to the self-limiting patron if requested.
• After the patron has completed the form the designated Security representative will review the form for accuracy and verify information recorded by the self-limiting patron.
REQUEST TO SELF-LIMIT SERVICES (2)• A copy of the completed exclusion form will be provided to the Marketing
Department. Once received by Marketing then a database representative will enter notations on the restricted services into the database. In addition, if direct mail services are suspended then the patron will be marked “NO MAIL” in the system and all direct mail marketing will be discontinued within 90 days.
• The Database representative will add any correlative remarks into the system. Once the remarks have been entered into the system then the Marketing Department will send confirmation to the Director of Compliance to be placed in the excluded patron’s file.
• Once a Cage/Credit representative has received notice of restricted credit or check cashing services then a review will be conducted of the database notations to ensure appropriate comments have been recorded relative to the self-limiting patron’s request. If comments have not been entered into the system then the Cage/Credit department representative will enter all relative information into the system.
• Prior to issuance of credit or check cashing services all relative personnel will reference the database to identify any patron with restricted services.
• Information on the patron requesting exclusion along with a copy of the “Request to Self-Limit Services” form will be forwarded to the following departments and the form will be retained with the self-limiting patron’s records:
REQUEST TO SELF-LIMIT SERVICES CONTINUED
1.Marketing/ Database2.Security3.Compliance4.Cage/Credit Office5.Slots6.Players Club7.Surveillance8.Table Games9.General Manager
REQUEST FOR REINSTATEMENT OF ACCESS OR PRIVILEGES:
Anyone who completes a Request to Self-Limit Access or Privileges form will be considered a permanent eviction. Any patron may complete a “Request to Reinstate Access or Services” form, which will be reviewed by the General Manager.
SELF-EVICTION CHECK LIST
Please Complete Checklist for Self-Limit Access
• _____Notify Surveillance• _____Players Club Card or call to obtain #• _____Copy Valid ID for verification• _____Complete Patron’s Self Limit Access Form – (patron sign
and dated)• _____Photo patron (make 8 copies – forward to each
department)• _____Sign and date form (date received – Manager/Supervisor)• _____Give patron copy• _____Fax Gaming Security Report
SELF-EVICTION CHECK LIST CONTINUED
Security Supervisor/Manager______________ Date:______ Date:______
Director of Compliance __________________ Date:_____ Date:______
Cage/Credit Department_________________ Date:______ Date:______
Slot Supervisor/Manager_________________ Date:______ Date:______
Surveillance___________________________ Date:______ Date:______
Players Club __________________________ Date:______ Date:______
Marketing_____________________________ Date:______ Date:______
Database Manager/Rep.__________________ Date:______ Date:______
Table Games Department ________________ Date:______ Date:______
General Manager_______________________ Date:______ Date:______
SELF EVICTION / PROPERTY EVICTION ACTIVITY LOG
DATE: _____________________________________
NAME: ____________________________________
Player Club Rewards # : _______________________________
SOCIAL SECURITY #: _______________________
DATE OF BIRTH: ___________________________
Date of Activity Comments on Activity
Your training packet includes examples of forms and procedures to
acknowledge an evicted patron has come on to our property
Trespasser Acknowledgement
Our pre-opening Demand Stimulation Marketing Plan can be divided into three
segments:
I. Build Awareness
The first goal of our pre-opening strategy is to build awareness of our product and for
the community to first and foremost know what we are building. We will do this by
introducing the bricks and mortar of the property – slots, table games, poker room,
great restaurants, a 100,000 square foot event center and an equine center.
As we build awareness of our product, it is equally important that we introduce our
brand and our core company values of Service, Quality and Community. We are
committed to providing customer service that will exceed customers‟ expectations
beginning with a sincere greeting as they arrive, prompt, courteous service during their
visit, and a fond farewell. We want our customers to know that we are committed to a
quality experience, from the ingredients in our food product, the finishes of the
property‟s design, to our attention to detail in everything we do. And we want them to
know that we will be active members of our community and we will be active
supporters of worthwhile causes.
We will use social media, public relations and mass media to get our message out. Our
website and social media platforms have already launched and our public relations
team is already on board. Our outdoor campaign will start to appear almost
immediately after approval. An aggressive television, print, radio and internet
advertising campaign will be launched approximately 90-days prior to opening – and
will intensify as the grand opening approaches. Our pre-opening expenditures are
budgeted at $1,603,000.
We also plan to use direct mail to stimulate
trial. We do not subscribe to the „build it
and they will come‟ principle. We believe
aggressive marketing efforts are necessary
from day one. Our research shows that we
can mail offers to approximately 50,000
unique households of potential customers.
Social media will be a key resource
that we use to create awareness.
Social media outlets like Twitter,
Facebook and a personalized
YouTube channel provide us with
great platforms to build a community
of influencers that will recommend our
product for trial.
II. Generate Trial
The next step is to generate trial. Our company website, www.kansasstar.com is an
excellent source of information about our facility. Our website will be continually
updated with current, relevant information such as construction progress updates,
announcements of milestone
events and company and
community developments. We
will also actively solicit
membership into our player‟s
club via this website.
Our goal is to have 20,000 players in our database before we open our doors. We will
establish kiosks in regional, high-traffic locations where players can learn first-hand, in a
highly visual manner, about our property and the amenities that we will offer. They will
also begin to learn the benefits of player‟s club membership and can enroll in the club
on the spot. Their personalized cards will be mailed to them prior to opening. To create
a compelling reason for people to sign-up, we will offer unique opportunities, including
providing our inaugural group of members with a special, limited edition player‟s club
card; they will be entered into “members only”
drawings and have a chance to receive
exclusive invitations to special events including
the Grand Opening Gala.
During our trial period we will establish a robust sales team. The sales team will be
responsible for booking group tour and travel business and establishing key relationships
within the community. The ideal candidates for these positions will be current
community leaders – people that have established important contacts in the area and
understand the unique nature of local customers.
III. Create Loyalty
We understand that our first few months of operation are critical to the continued
success of the property. We are confident that with the skilled use of public relations,
media savvy and creative marketing efforts we will generate trial for our facility. This
trial will come from a myriad of different audiences; from the first time casino visitor to
the experienced player currently visiting our competitors. Through the completion of
proven training programs, our team members will be ready to welcome these
guests. Our quality of design and the experience that we provide will convert these trial
visitors into long standing, loyal customers.
In addition to learning the skills required to excel in their specific jobs, an important part
of our new hire training program will be to teach our team members the importance of
our company core values. We believe that our team members come first. And we
know that if we treat them right, they will be our strongest advocates and ultimately
provide excellent service for our guests. Keeping them informed of the details of our
project will be a key to our eventual success. They will be instrumental in getting the
word out – in fact they will be our best advocates to generate trial among their circle of
friends and family members.
Our player‟s club will be developed with loyalty in mind. Like most players clubs,
customers will earn food offers, room discounts, invitation to special events and show
tickets for their level of play. But our player‟s club is unique, members will be able to
earn and redeem their points both at the casino and within our network of strategic
business partners in the community. We will begin to establish these community
anchors well before our opening date. This too will create opportunities for these
strategic partners to endorse our product through their circle of influence.
We are confident that we have the resources, ingenuity and experience to execute a
highly successful pre-opening demand stimulation marketing plan.
